March 2017

A joint international investigation, involving Australia, Germany, the UK and the Netherlands, has led to several arrests and an increase in inquiries against individuals involved in tax evasion that are linked to Swiss bank accounts at Credit Suisse.

Uber could be forced to pay millions of pounds in indirect tax if the UK High Court decides that the company should be charging VAT on its services. HMRC could also face questions as to why it did not take action at the first opportunity.

Brazilian tax authorities and taxpayers have long contested the inclusion of ICMS (a tax on the circulation of goods, interstate and intercity transportation and communication services) when calculating COFINS and PIS contributions, two complex social taxes.

The EU Parliament’s Economic and Monetary Affairs Committee (ECON) has accepted proposals to end the use of hybrid mismatch arrangements by multinationals, but has made several amendments to expand the rules.

Amazon has triumphed over the US tax authority after the US Tax Court ruled in favour of the online retailer in a tax dispute involving Amazon’s use of a Luxembourg subsidiary for its European operations and transfer pricing arrangements.

As the EU takes the first major step towards introducing public country-by-country reporting (CbCR), many are asking what the EU’s plan really means. Keith Brockman considers the vision of the latest proposal.

Countries worldwide have followed Mexico’s lead to tax sugar-sweetened drinks in an effort to curb obesity and unhealthy habits, but these measures are coming at a cost to manufacturers and may not be as profitable for governments as they suggest.

Dealing with the known unknowns is all any business can seek to do in the uncertain environment, whether it stems from the US or the UK. Cormac Kelleher, international tax partner at Mazars in Dublin discusses the plethora of unknowns and how companies can navigate through it all.

The world is on the cusp of a major tax revolution as cryptocurrencies and online distributed ledger technologies, such as blockchain, push financial systems from the physical world to online. Amelia Schwanke speaks to the experts in a roundtable discussion about the tax implications and usage of digital currencies and blockchain.

There has been a complete paradigm shift in global taxation with the rise in audit risks caused by new global initiatives like the OECD’s BEPS Project. JD Choi, CEO at Tax Technologies, explores the technology solutions that should be administered to mitigate these audit risks in a post-BEPS world.

The US tax system is on the brink of change as upcoming discussions centre on tax policy (including regulations related to inversion transactions) that will ultimately reshape the US tax treatment of inter-company financing within MNEs. In the second half of 2016, a stream of new regulations and law changes, both actual and proposed, in and outside of the US, created new issues for inter-group financing by multinationals. Stuart Chessman, director at Vivendi, discusses the salient points.

Canada’s Finance Minister William Morneau plans to make drivers using ride-sharing apps, such as Uber, register and charge sales taxes on their taxi services as part of his fairer tax measures announced in the federal budget that target commercial activities.

Canada’s 2017 federal budget will be unveiled on March 22 and it is very likely to contain tax changes affecting businesses as the government looks to address economic challenges and maintain the country’s competitive edge.

In a humiliating change of events, UK Chancellor of the Exchequer Philip Hammond ditched his proposals – announced only a week ago – to increase Class 4 national insurance contributions (NICs) for the self-employed and target gig economy workers, relieving many taxpayers of a higher tax burden.

Antoine Deltour, one of the two whistleblowers at the centre of the LuxLeaks scandal, said that he had “mixed feelings” after his conviction for leaking confidential information was upheld, but his sentence was reduced.

In a massive blow to tax transparency and whistleblower campaigners, Antoine Deltour and Raphaël Halet have failed in their quest to be acquitted for the LuxLeaks scandal in an appeal against an earlier verdict.

ITR breaks down the developments that led to the conviction of former PwC employees Antoine Deltour and Raphaël Halet, who exposed more than 300 multinational enterprises benefiting from sweetheart tax deals with the Luxembourg authorities to avoid taxes in Europe.

Recent studies show that the African continent is attracting a growing amount of investments from foreign multinational enterprises. BonelliErede and International Tax Review will provide an overview of the main transfer pricing issues to consider for structuring investments into selected countries.

Companies operating in Russia should urgently re-assess their tax structures after one of the country’s courts delivered a landmark decision concerning substance in a cross-border M&A deal, creating serious risks for corporate restructuring.

US officials raided three sites belonging to multinational manufacturer Caterpillar as part of an investigation into its offshore tax practices that were allegedly used to shift billions of dollars of profit abroad to avoid US taxes.

Tax transparency activists are rejoicing after MEPs in the European Parliament passed amendments to the EU Anti-Money Laundering Directive that allow public access to registers containing the details of the beneficial owners of companies and trusts.

The EU will lead the way in defining how countries worldwide will implement rules to stop the use of hybrid mismatch arrangements in line with BEPS Action 2 after the Economic and Financial Affairs Council (ECOFIN) agreed its position on the rules to prevent the practice with the tax systems of non-EU countries.